Shaffer v. Commissioner of Revenue

CourtMassachusetts Supreme Judicial Court
DecidedJuly 10, 2020
DocketSJC 12812
StatusPublished

This text of Shaffer v. Commissioner of Revenue (Shaffer v. Commissioner of Revenue) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Shaffer v. Commissioner of Revenue, (Mass. 2020).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-12812

M. CHRISTINE SHAFFER, executrix,1 vs. COMMISSIONER OF REVENUE.

Suffolk. February 10, 2020. - July 10, 2020.

Present: Gants, C.J., Lenk, Gaziano, Lowy, Budd, Cypher, & Kafker, JJ.

Taxation, Estate tax, Trust. Trust, Taxation. Due Process of Law, Taxation. Words, "Transfer," "Massachusetts gross estate."

Appeal from a decision of the Appellate Tax Board.

The Supreme Judicial Court granted an application for direct appellate review.

Leo J. Cushing (Jenna R. Wolinetz also present) for the taxpayer. Celine E. de la Foscade-Condon (John J. Connors, Jr., also present) for Commissioner of Revenue.

CYPHER, J. This case concerns whether the intangible

assets in a qualified terminable interest property (QTIP) trust,

which was created by the predeceasing spouse in New York, are

1 Of the estate of Adelaide P. Chuckrow. 2

subject to the Massachusetts estate tax, G. L. c. 65C, § 2A (a),

when the surviving spouse died domiciled in Massachusetts.

Adelaide P. Chuckrow (decedent), the lifetime income beneficiary

of the QTIP trust created in New York by her late husband Robert

Chuckrow (Robert), died domiciled in Massachusetts in 2011. The

decedent's estate (estate) included the value of the QTIP trust

assets in computing her Federal estate tax return, but not in

computing her Massachusetts estate tax return. The Commissioner

of Revenue (commissioner) selected the estate's Massachusetts

return for audit and assessed an additional Massachusetts estate

tax of $1,809,141.88, based on the value of the QTIP assets.

The Appellate Tax Board (board) upheld the assessment. The key

issue before us is whether the intangible assets in a QTIP trust

created by the predeceasing spouse when he was domiciled in a

different State are includable in the gross estate of the

Massachusetts domiciliary decedent for purposes of calculating

the Massachusetts estate tax under § 2A (a). We affirm the

decision of the board that there is not a constitutional or a

statutory barrier to the assessment of Massachusetts estate tax,

on the value of the QTIP assets.

Background. 1. Statutory framework. We begin with an

overview of the statutory framework, in order to provide context

to the following discussion. 3

a. Federal estate tax and Massachusetts estate tax. An

estate tax is a tax on the privilege of transferring property at

death. See Knowlton v. Moore, 178 U.S. 41, 56 (1900). Internal

Revenue Code § 2001(a) sets forth the Federal estate tax: "A

tax is hereby imposed on the transfer of the taxable estate of

every decedent who is a citizen or resident of the United

States." 26 U.S.C. § 2001(a). General Laws c. 65C, § 2A (a),

sets forth the Massachusetts estate tax. Following various

versions of the Massachusetts estate tax in response to the

changes in the Internal Revenue Code, in 2002, the Legislature

amended § 2A to use a "sponge tax" calculation2 based upon the

Federal credit for State death taxes that would have been

allowable to a decedent's estate in 2000. See G. L. c. 65C, §

2A (a); St. 2002, c. 186, §§ 28, 34; St. 2002, c. 364, §§ 10,

23. See also Department of Revenue, Technical Information

Release 02-18 (Nov. 6, 2002) ("reference point Massachusetts

uses to tie itself to the [Internal Revenue] Code for sponge tax

purposes is a fixed date instead of a reference point that

automatically incorporates any federal changes. Thus, due to

the decoupling legislation, the Massachusetts sponge tax is now

tied to the [Internal Revenue] Code as in effect on December 31,

2Under a "sponge tax," the State tax liability is determined based on the Federal estate death tax credit. See Ward v. Commissioner of Corps. & Taxation, 369 Mass. 3, 4 (1975). 4

2000"). The Massachusetts estate tax imposes a tax "upon the

transfer of the estate of each person dying on or after January

1, 1997 who, at the time of death, was a resident of the

commonwealth." G. L. c. 65C, § 2A (a).

b. Marital deduction. The marital deduction allows an

estate to deduct from the value of the taxable estate certain

property that passes or has passed from a decedent to the

decedent's surviving spouse. 26 U.S.C. § 2056(a). In general,

a marital deduction defers the estate tax on the property

subject to the marital deduction until the death of the

surviving spouse; it does not eliminate the tax liability

altogether. See Estate of Sommers v. Commissioner of Internal

Revenue, 149 T.C. 209, 223 (2017).

c. QTIP trust. An estate generally may not make use of

the marital deduction when conveying terminable interest

property (terminable interest rule). 26 U.S.C. § 2056(b)(1).

However, 26 U.S.C. § 2056(b)(7) provides an exception to the

terminable interest rule for QTIP. To become QTIP, (1) the

property must pass from the predeceasing spouse, (2) the

surviving spouse must have a qualifying income interest for life3

3 "The surviving spouse has a qualifying income interest for life if . . . (I) the surviving spouse is entitled to all the income from the property, payable annually or at more frequent intervals, or has a usufruct interest for life in the property, and (II) no person has a power to appoint any part of the 5

in the property, and (3) the executor of the estate of the

predeceasing spouse must elect to designate the property as

QTIP. 26 U.S.C. § 2056(b)(7)(B). Using a QTIP trust allows for

the deferral of the Federal estate tax on the assets used to

create the QTIP trust until the surviving spouse dies.4 See 26

U.S.C. § 2044. See also Estate of Clayton v. Commissioner of

Internal Revenue, 976 F.2d 1486, 1491-1493 (5th Cir. 1992)

(explaining history of marital deduction and QTIP).

2. Robert's creation of the QTIP trust. Robert died in

July 1993, while domiciled in New York.5 His last will and

testament established a trust for the decedent's benefit. The

trust qualified for a QTIP trust election under 26 U.S.C.

§ 2056(b)(7) and under New York law. At the time of Robert's

death, the trust assets totaled $844,101.27, and consisted

wholly of intangible property, including shares in various

companies and a fifty percent limited partnership interest in

Chuckrow Smith Associates, L.P.

property to any person other than the surviving spouse." 26 U.S.C.

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Knowlton v. Moore
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Graves v. Schmidlapp
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